NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.
In the Supreme Court of Georgia
Decided: January 21, 2026
S25A1213. WILLIAMS v. THE STATE.
LAGRUA, Justice.
Appellant Russell Williams, who pleaded guilty to malice
murder and other crimes in connection with the beating death of
Marcos Guerra-Lopez, appeals the trial court’s denial of his motion
to withdraw his guilty plea. 1 On appeal, Williams argues that the
————————————————————— 1 The crimes occurred on December 7 and 9, 2018. On February 27, 2019,
a Gwinnett County grand jury indicted Williams and co-indictees Zarius Jajuan Williams and Glenda Victoria Carter, individually and as parties to a crime, for malice murder (Count 1); felony murder predicated on armed robbery (Count 2); felony murder predicated on aggravated battery (Count 3); felony murder predicated on aggravated assault (Count 4); armed robbery (Count 5); aggravated battery (Counts 6, 10, and 11); aggravated assault (Counts 7, 8, 12, and 13); and criminal intent to commit armed robbery (Count 9). On April 26, 2023, Williams entered a non-negotiated guilty plea to all counts. The trial court sentenced Williams to life with the possibility of parole on Counts 1 and 5, to run concurrently; and 20 years in confinement on each of Counts 9–12, to run concurrently with Count 1. The remaining counts merged or were vacated by operation of law. On May 4, 2023, Williams was appointed new counsel, and on May 23, 2023, counsel filed a motion to withdraw Williams’s guilty plea. On March 12, 2025, the trial court held an evidentiary hearing on the motion, and the trial court entered an order denying the motion on May 1, 2025. Williams filed a timely notice of appeal to this Court, and the case was docketed in this Court to the August 2025 term and submitted for a decision on the briefs. trial court erred in denying his motion to withdraw his guilty plea
because (1) he did not knowingly, voluntarily, and intentionally
waive the rights mentioned in Boykin; 2 and (2) his plea counsel was
constitutionally ineffective by coercing him to enter a guilty plea. As
explained below, these claims fail. Accordingly, we affirm the trial
court’s denial of Williams’s motion to withdraw his guilty plea.
However, because the trial court committed sentencing errors, we
remand the case to correct the sentence.
Williams’s trial began on April 24, 2023. On the third day of
trial, Williams’s co-indictee and brother, Zarius, testified against
him, and Williams’s other co-indictee, Carter, was scheduled to
testify after Zarius. 3 However, after Zarius testified, Williams
decided to enter a plea. The trial court then conducted a plea
hearing, and during the hearing, the prosecutor recited the following
facts4: On December 7, 2018, Guerra-Lopez went to an apartment,
————————————————————— 2 Boykin v. Alabama, 395 US 238 (1969). 3 Prior to Williams’s trial, Zarius and Carter both pleaded guilty and
were sentenced to life with the possibility of parole. 4 The record does not include any testimony from Williams’s trial. As
such, this factual background is limited to the facts offered in the prosecutor’s 2 where he expected to meet Carter. When Guerra-Lopez arrived,
Williams and Zarius were hiding in a closet. Williams and Zarius,
who was armed with a bat, repeatedly struck Guerra-Lopez, who
later died from blunt-force trauma to the head. Williams, Zarius,
and Carter then stole a cell phone and money from Guerra-Lopez.
Williams, Carter, and Zarius left the apartment and used the
stolen money to buy food. Williams later invited another person,
Simon Fuentes, to the same apartment where Guerra-Lopez was
killed. When Fuentes arrived at the apartment on December 9, 2018,
Williams held a knife to Fuentes’s throat while Zarius hit Fuentes
with a bat. Fuentes fought back and escaped the apartment, drove
away, and got help. Law enforcement subsequently apprehended
Williams and found a knife, Guerra-Lopez’s wallet, and Guerra-
Lopez’s identification card in Williams’s vehicle. Law enforcement
also recovered Guerra-Lopez’s phone, which was found in the hotel
room where the suspects were apprehended.
During the plea hearing, Williams testified that he understood
————————————————————— proffer from the guilty plea hearing. 3 the charges that he was facing. The State then asked the following
questions:
[PROSECUTOR]: Do you understand that there are certain rights that you’re entitled to have and by coming forward and entering a plea of guilty you’re essentially waiving those rights? Those rights include the right to a trial by jury, the right to be presumed innocent, the right to confront any witnesses against you, the right to subpoena witnesses for your defense, the right to testify yourself as well as offer any other evidence, the right to have an attorney assist you throughout trial, and the right to not incriminate yourself. Do you understand that you’re waiving those rights today?
[WILLIAMS]: (No response.)
[Whereupon an off-the-record discussion was held between Williams and his counsel.]
After Williams spoke to his plea counsel,5 the trial judge
advised Williams that the trial court would not “mind continuing on
with this trial to its conclusion” but that Williams’s plea counsel
indicated Williams wanted to enter a plea. The following exchange
then occurred:
[TRIAL JUDGE]: If you don’t want to do that, that’s fine, let’s continue on with the trial. If you want to do that, I’m going to need you to listen carefully to the questions that ————————————————————— 5 Williams’s plea counsel also represented Williams during his jury trial.
4 are being asked of you, and I’m going to need you to answer loudly so that everyone can hear and that we can make a record of these proceedings. Do you understand me?
[WILLIAMS]: Yes, sir. Yes, your Honor.
[TRIAL JUDGE]: In fact, do you want to go ahead and enter a plea of guilty to these charges?
[WILLIAMS]: It’s in my best interest, Judge.
The trial judge asked the prosecutor if the State would accept
an Alford6 plea, and the prosecutor indicated that the State was
willing to do so. The trial judge then described the nature of an
Alford plea and again asked Williams if he wanted to continue with
a “best-interest plea,” to which Williams responded, “Yes, sir.”
Following that response, the prosecutor asked Williams, “Do you
understand that if you were to plead not guilty or [do] not enter a
plea at all then we would go ahead and proceed with the jury trial?”
Williams responded, “Yes, ma’am.” The prosecutor then detailed the
following on the record: (1) the minimum and maximum
————————————————————— 6 See North Carolina v. Alford, 400 US 25 (1970).
5 punishments for each of the charges that Williams was facing; (2)
the nature of a non-negotiated guilty plea in which the trial judge
determines the sentence; and (3) the possible conditions of probation
if the trial judge were to include probation in the sentence. For all
three, Williams stated that he understood.
Next, the prosecutor asked Williams if “anyone forced
[Williams] or promised [Williams] anything in exchange for entering
this plea of guilty here today?” Williams responded, “Yes,” and the
prosecutor then asked, “Someone has forced you to enter a plea of
guilty?” Williams again responded, “Yes.” The trial judge
interjected, stating the following:
Okay. Sir, basically, we have got to have a plea that you are doing of your own free will. I understand that things have changed here in the courtroom during the course of the trial, but I cannot accept a plea that somebody says is being forced upon them. This has to be your decision and your decision alone. So if your response is that somebody is forcing you to enter this plea, then we’re going to need to continue on with the trial of this case.
Williams and his plea counsel then had another off-the-record
conversation, and when it concluded, the following exchange
6 occurred:
[PLEA COUNSEL]: Are you being forced to enter this plea?
[WILLIAMS]: I’m good, Judge.
[TRIAL JUDGE]: I’m sorry?
[WILLIAMS]: I’m good.
[PLEA COUNSEL]: Well, you haven’t answered the question. Are you being forced to enter the plea?
[WILLIAMS]: No.
[TRIAL JUDGE]: Okay. So, Mr. Williams, I want there to be a record of what’s going on here today. Other than what is going on in terms of the evidence that has been produced in this case, is anyone or anything forcing you to enter this plea or putting pressure on you to enter this plea?
[TRIAL JUDGE]: And is this your decision to enter a best- interest plea of guilty to all 13 counts of the indictment?
[PLEA COUNSEL]: You need to answer the question.
[Whereupon, an off-the-record discussion was held between Williams and his counsel.]
7 [TRIAL JUDGE]: Is that your decision?
[PLEA COUNSEL]: You have to answer the judge’s question.
[WILLIAMS]: Yes, Judge.
Following that exchange, the prosecutor asked Williams if he
was satisfied with his plea counsel, and Williams indicated that he
was. Williams and his plea counsel then had another off-the-record
conversation. Afterwards, Williams affirmed that he had enough
time to speak to his plea counsel and that he was entering the guilty
plea both freely and voluntarily. The prosecutor then reiterated the
nature of an Alford plea and asked Williams if he wanted to proceed
with the Alford plea, to which Williams responded, “Yes, ma’am.”
The prosecutor also detailed Williams’s appellate and habeas corpus
rights, and Williams affirmed that he understood those rights.
After argument from plea counsel, Williams made a statement
to the trial judge, which included the following remarks: “I just want
to let you know, your Honor, that I’m not a murderer. I’m not who
they’re trying to accuse me of being.” The following exchange then
8 occurred:
[TRIAL JUDGE]: So, Mr. Williams, we are here in trial. It’s now 12:40 on the third day of trial. The jury is still in the deliberation room, expecting to come back here and continue with the trial of the case, if that’s what you want. Do you understand what I just told you?
[WILLIAMS]: Yes, your Honor.
[TRIAL JUDGE]: And we’ve had some discussions. We’ve cleared the courtroom so that you could speak with your stepfather after your brother, Zarius Williams, gave his testimony. And you had that opportunity, correct?
[TRIAL JUDGE]: So this is your opportunity at this point in time to basically continue on with the trial, if that’s what you want to do. Do, in fact, you want to continue on with this trial?
[WILLIAMS]: No, your Honor.
[TRIAL JUDGE]: Do you need any more time to talk to your attorney before we conclude this matter?
[WILLIAMS]: Yes, your Honor, if that’s all right with the Court.
The trial judge asked Williams if he would like to speak to his
plea counsel in the back of the courtroom. Williams indicated he
would, but while the trial judge was arranging to clear the back of
9 the courtroom, Williams’s plea counsel said, “Judge, he said he
didn’t need any more time.” The trial judge asked Williams if he was
sure, and the trial transcript reflects that Williams nodded his head.
The following exchange then occurred:
[TRIAL JUDGE]: I want you -- I want you to have as much time as you need, Mr. Williams, because this is an important decision. So if you need more time, I’m willing to give you that time. Do you need more time to talk to your attorney?
[WILLIAMS]: We can proceed, your Honor.
[TRIAL JUDGE]: Do you need more time to talk to your attorney?
[TRIAL JUDGE]: Are you sure?
[WILLIAMS]: Yes, sir.
[TRIAL JUDGE]: Do you want me to accept your plea as a best-interest plea?
[TRIAL JUDGE]: Do you have any questions or concerns about entering that plea?
10 The trial judge accepted Williams’s guilty plea, determining it
was “freely, voluntarily, and intelligently entered based upon the
responses [Williams had] given to the questions that were asked of
[Williams].” After sentencing Williams, the trial judge asked
Williams if he had any questions concerning the sentence, and
Williams stated that he did not.
Following entry of the final disposition, Williams, represented
by new counsel, timely filed a motion to withdraw his guilty plea. In
the motion, Williams claimed that withdrawal should be permitted
because (1) he did not waive the rights mentioned in Boykin, (2) his
plea counsel was ineffective, and (3) his plea was not voluntary. At
a hearing on Williams’s motion to withdraw his guilty plea, both
Williams and his plea counsel testified.
Williams’s plea counsel testified that, when the trial stopped
and the plea hearing commenced, he believed there was sufficient
evidence to convict Williams. According to plea counsel, Williams
“didn’t want to enter the plea when [they] were having discussions
initially” and “continually maintained that he was not a murderer.”
11 Plea counsel then explained to Williams that, “under the law as a
party to a crime,” Williams would probably be convicted “because
the evidence was overwhelming.” Plea counsel testified that he
believed it was in Williams’s best interest to enter a plea, but
Williams did not want to enter a plea and felt pressure to do so.
Nevertheless, plea counsel confirmed that the decision to enter a
plea ultimately belonged to and was made by Williams.
Plea counsel also testified that he had represented criminal
defendants in over 100 jury trials and had handled thousands of
guilty pleas. Additionally, before trial, Williams received a mental
evaluation and was determined to be competent to stand trial. Plea
counsel reviewed all the discovery and discussed the case with
Williams prior to trial, and plea counsel noted that he found
Williams to be “thoughtful and intelligent.” At trial, after Zarius
testified and inculpated Williams, plea counsel told Williams, “[I]t’s
over.”
Plea counsel further testified that, in his conversation with
Williams at the plea hearing, he never threatened or physically
12 touched Williams, and he did not force Williams to enter a plea. Plea
counsel also stated that, when discussing the plea with Williams, he
understood Williams’s “position” regarding the plea but noted that
Williams’s “position [wa]s not supported by the law [related to party-
to-a-crime].” Plea counsel testified that Williams “didn’t seem
confused, just more so, you know, really apprehensive and, you
know, remorseful that it had gotten this far.” Plea counsel said he
was confident Williams understood the nature of a guilty plea,
despite his reluctance to enter a plea.
Following the testimony from Williams’s plea counsel,
Williams testified at the plea hearing as follows: After Zarius
testified at trial, Williams was reluctant to enter a plea, but his plea
counsel was “forceful” and “overbearing” in “pressuring” him to do
so. Williams affirmed that his plea counsel spoke to him in a “harsh
manner,” but Williams denied that plea counsel ever used “profane
language” towards him. Williams testified that he did not want to
enter the plea because he did not believe he was a murderer, and he
felt “coerced” to enter a plea. Williams indicated that, when he
13 entered the plea, he did not understand that he was waiving his
right against self-incrimination, right to question witnesses, and
right to remain silent. Williams testified that he did not voluntarily
enter his plea, and he would have continued with trial if not for his
plea counsel’s actions.
However, Williams also conceded that he recalled (1) telling the
trial judge that it was in his “best interest” to enter a plea; (2)
hearing the maximum penalties for each charge; and (3) and hearing
the trial judge say that the court was prepared to continue with the
trial. When asked whether he recalled telling the trial judge that he
was not being forced to enter a plea, Williams responded: “Yeah. I
only said that because [plea counsel] didn’t want to continue on with
the trial. He already said that he didn’t want to fight the case. He
said the case was over with. He said he really didn’t want to be here.”
Williams testified that, when asked at the plea hearing if he
was being forced to enter a plea, his response was initially “yes,” but
he later changed it to “no” because his plea counsel was “trying to
get [him] to sign [the plea form],” which he reluctantly signed. When
14 asked at the motion hearing if he was satisfied with the services of
his plea counsel, Williams testified, “I guess so.”
The trial court subsequently denied Williams’s motion to
withdraw his guilty plea, concluding as follows: “Prior to entering
his guilty plea, [Williams] was appropriately advised of his rights
and the [trial court] found that he understood those rights. The
testimony presented during [the] hearing does not cause the [trial
court] to alter its conclusion.”
1. Williams argues on appeal that the trial court abused its
discretion in denying his motion to withdraw his guilty plea because
he did not knowingly, voluntarily, and intentionally waive the rights
listed in Boykin. This claim fails. 7
“After sentencing, a defendant may withdraw his guilty plea
only to correct a manifest injustice.” Hood v. State, 315 Ga. 809, 812
————————————————————— 7 Williams raises additional arguments for the first time in his reply
briefs, but “[a]n appellant who raises an argument for the first time in a reply brief is not entitled to have that argument considered.” City of Atlanta v. Mays, 301 Ga. 367, 372 (2017); see also Williams v. State, 307 Ga. 689, 689 n.2 (2020).
15 (2023). We have said that “withdrawal is necessary to correct a
manifest injustice if, for instance, a defendant is denied effective
assistance of counsel, or the guilty plea was entered involuntarily or
without an understanding of the nature of the charges.” Id. (citation
omitted).
“[A] guilty plea is valid as a matter of federal constitutional law
if the record affirmatively shows that it is voluntary and intelligent
under the totality of the circumstances.” Green v. State, 318 Ga. 610,
636 (2024). “A voluntary and intelligent guilty plea is one that is
made of the defendant’s own choice with sufficient awareness of the
relevant circumstances and likely consequences.” Id. at 615–16
(quotation marks omitted). Such relevant circumstances and likely
consequences typically “include the nature of the charge to which
the defendant is admitting guilt, the factual basis of the charge, the
punishment to which the plea will expose him, the terms of any
negotiated agreement with the government, and the rights the
defendant will waive by entering the plea.” Id. at 616.
We have explained that, “[w]hen reviewing a trial court’s
16 determination that a defendant’s plea was knowing and voluntary,
we review the court’s factual findings for clear error, but the
ultimate determination is reviewed de novo.” Harris v. State, 319
Ga. 133, 137 (2024). And we will not disturb a trial court’s decision
on a motion to withdraw a guilty plea “absent an obvious abuse of
discretion.” Wright v. State, 314 Ga. 355, 358 (2022) (quotation
marks omitted). “A trial court does not abuse its discretion in
denying a motion to withdraw a guilty plea if the record supports
the trial court’s determination that a plea was made knowingly,
intelligently, voluntarily, and without coercion.” Powell v. State, 309
Ga. 523, 524–25 (2020).
Here, the record shows that Williams entered a voluntary and
intelligent guilty plea. As the trial court found, Williams “was
appropriately advised of his rights and … understood those rights”
prior to entering his guilty plea. The trial court’s conclusion is
supported by the record, which shows that, at the plea hearing, the
prosecutor described the factual basis for the plea as well as the
rights that Williams would waive by pleading guilty; Williams
17 affirmed that he understood the nature of the charges to which he
was pleading guilty, the minimum and maximum punishments for
each of those charges, and the nature of a non-negotiated guilty plea;
and Williams was allowed to speak to his plea counsel at five
different points. Further, the trial court engaged in multiple
colloquies with Williams to ensure that he wanted to enter a plea
instead of continuing with the trial. During one of these colloquies,
after Williams initially indicated that he was being forced to enter a
plea, the trial court probed further, and Williams denied that anyone
was forcing or pressuring him to enter a guilty plea. Additionally,
Williams confirmed that he was entering his plea freely and
voluntarily, and he told the trial court that it was in his best interest
to enter a guilty plea. Thus, although Williams may have been
hesitant to enter a guilty plea, the record shows that, under the
totality of the circumstances, his plea was intelligently and
voluntarily entered. See Green, 318 Ga. at 636.
Williams also argues that the record does not affirmatively
show that he waived the rights mentioned in Boykin, and the trial
18 court therefore abused its discretion in denying his motion to
withdraw his guilty plea. This argument is unpersuasive. We have
explained that the failure to advise an accused of the rights listed in
Boykin “does not require the reversal of a guilty plea where the
longstanding intelligent and voluntary standard has otherwise been
met.” Green, 318 Ga. at 637 (quotation marks omitted). Moreover,
the record shows that Williams was advised of these rights despite
his non-response after the prosecutor asked whether he understood
that he would be waiving those rights by pleading guilty. And, as set
forth above, the record shows that Williams’s guilty plea was
voluntary and intelligent under the totality of the circumstances. As
such, Williams has not shown that the trial court abused its
discretion in denying his motion to withdraw his guilty plea on the
basis that he did not affirmatively waive the rights listed in Boykin
on the record at the plea hearing.
2. Williams also argues on appeal that the trial court erred in
denying his motion to withdraw his plea on the basis that his plea
counsel was constitutionally ineffective by coercing him to enter a
19 guilty plea. This claim fails.
As noted above, “[a]fter sentencing, a defendant may withdraw
his guilty plea only to correct a manifest injustice,” Hood, 315 Ga. at
812, and “[i]neffectiveness of counsel can constitute manifest
injustice requiring that a defendant be allowed to withdraw his
plea.” Powell, 309 Ga. at 526. To establish a claim of ineffective
assistance of counsel, Williams “must show both that his plea
counsel’s performance was constitutionally deficient and that the
deficient performance prejudiced his defense.” Wright, 314 Ga. at
357 (citing Strickland v. Washington, 466 US 668, 687 (1984)).
“To meet the first prong of the Strickland test,” Williams “must
overcome the strong presumption that counsel’s performance fell
within a wide range of reasonable professional conduct, and that
counsel’s decisions were made in the exercise of reasonable
professional judgment.” Hood, 315 Ga. at 812 (quotation marks
omitted). For the second prong of the Strickland test, Williams
“must demonstrate that there is a reasonable probability that, but
for counsel’s errors, he would not have pleaded guilty and would
20 have insisted on going to trial.” Id. at 813. As we have explained,
“where the defendant is unable to establish that counsel performed
deficiently, the inquiry ends, and it is not incumbent upon this Court
to examine the prejudice prong.” Goodwin v. State, 319 Ga. 842, 845
(2024).
Further, “[t]his Court accepts a trial court’s factual findings
and credibility determinations on an ineffectiveness claim unless
they are clearly erroneous, but we apply legal principles to the facts
de novo.” Powell, 309 Ga. at 526–27. “And in the absence of explicit
factual and credibility findings by the trial court, we presume
implicit findings were made supporting the trial court’s decision.”
Davis v. State, 306 Ga. 430, 432–33 (2019).
Here, Williams has not shown that his plea counsel was
deficient. Williams asserts on appeal that he received ineffective
assistance of counsel because his plea counsel “spoke to [him]
harshly, argued with him, raised his voice, and used curse words in
directing him to take the plea, causing [him] to be coerced into
entering the plea of guilty while under duress.” In his testimony at
21 the hearing on the motion to withdraw his guilty plea, Williams
stated that his plea counsel “was constantly pressuring [him] just to
sign this plea that [he] was reluctant to sign.” Williams further
testified that this pressure was “overbearing” and “forceful” because
Williams “didn’t want to sign [the plea agreement].” However,
Williams also denied that his plea counsel used “profane language.”
When plea counsel testified at the hearing, he stated that he
“never forced [Williams] to enter a plea,” and he was confident that
Williams understood the nature of a guilty plea despite Williams’s
reluctance to enter a plea. Additionally, although plea counsel
testified that he “fuss[ed] at” and “argue[d] with” Williams; was
“forceful” in his position regarding the plea; likely raised his voice;
and “may have cursed” during the conversation, plea counsel stated
that he did not threaten or physically touch Williams. And, while
plea counsel indicated that he believed it was in Williams’s best
interest to enter a plea, he also stated that it was ultimately
Williams’s decision whether or not to do so.
Thus, in denying Williams’s motion to withdraw his guilty plea,
22 it is clear that the trial court implicitly credited plea counsel’s
testimony over Williams’s in finding that plea counsel’s
representation was not constitutionally deficient, and our review of
the record supports this implicit finding. See Goodwin, 319 Ga. at
845 (noting that the trial court was entitled to disbelieve the
defendant’s testimony and to credit plea counsel’s testimony).
Moreover, to the extent Williams argues that he was coerced into
pleading guilty because his plea counsel “spoke to [him] harshly,
argued with him, raised his voice, and used curse words,” Williams
does not cite any Georgia cases supporting this proposition, and we
have found none. 8 The record shows that Williams entered his plea
freely and voluntarily—without coercion. Accordingly, the trial
court did not err in concluding that Williams’s plea counsel was not
ineffective and denying Williams’s motion to withdraw his plea on
————————————————————— 8 For this argument, Williams does not cite any legal authority other
than Rules 1.4 and 2.1 of the Georgia Rules of Professional Conduct found in Bar Rule 4-102(d). As we have explained, however, “[a]n ethics violation ... does not necessarily establish a claim of ineffectiveness of counsel.” Moore v. State, 306 Ga. 532, 537 (2019) (citing Blackshear v. State, 274 Ga. 842, 843 (2002)). Although “compliance with the Rules of Professional Conduct should always be maintained, attorney discipline for a violation of those Rules is not before us.” Green v. State, 299 Ga. 337, 342 (2016). 23 this basis. As such, this claim fails.
3. Although Williams did not raise an issue with his sentence
on appeal, we conclude that the trial court erred in sentencing
Williams on Counts 11 and 12, and because the sentencing error
penalizes Williams, we exercise our discretion to correct the error.
See Dixon v. State, 302 Ga. 691, 697 (2017) (“For this reason, an
exercise of our discretion on direct appeal to correct a merger error
that harms a defendant (but of which he has not complained) may
avoid unnecessary habeas proceedings and thereby promotes
judicial economy.”). Here, the trial court sentenced Williams for the
aggravated battery of Fuentes (Counts 10 and 11) and the
aggravated assault of Fuentes (Count 12). Because the injuries
sustained by Fuentes—as alleged in Counts 10 through 13 of the
indictment—occurred during a single, uninterrupted act, Counts 11
and 12 should have merged with Count 10.9 See Douglas v. State,
303 Ga. 178, 183 (2018) (concluding that two counts of aggravated
battery and one count of aggravated assault should have merged
————————————————————— 9 The trial court properly merged Count 13 with Count 10 at sentencing.
24 because the “injuries were sustained by one victim during a single,
uninterrupted criminal act”). We therefore vacate Williams’s
convictions and sentences on Counts 11 and 12. See id.
Judgment affirmed in part and vacated in part. All the Justices concur.